Justia Wyoming Supreme Court Opinion Summaries

A newborn child was taken into protective custody shortly after birth due to testing positive for methamphetamine and being abandoned by her mother at the hospital. The mother did not return, and the Department of Family Services (Department) was given custody. The child’s father was identified but was incarcerated at the time. Paternity was later confirmed. The Department developed a case plan for the father, which included requirements related to mental health, substance abuse, parenting, housing, and compliance with criminal proceedings. Because the father remained incarcerated, most aspects of his case plan could not be completed. He was able to participate in video visits and some treatment programs while in custody, but could not demonstrate sobriety or stability in the community.After the child was adjudicated neglected, the District Court of Natrona County initially ordered a permanency plan of reunification, contingent on successful completion of the case plan. Throughout the following year, the Department and multi-disciplinary team periodically reviewed the case. As months passed and the father’s release date remained uncertain, the Department recommended a concurrent plan of adoption. At a permanency hearing, evidence showed that, despite the father’s efforts within the limits of incarceration, reunification would require many more months, delaying stability for the child.The Supreme Court of Wyoming reviewed whether the district court abused its discretion by changing the permanency plan from reunification to adoption. The court held that the district court did not abuse its discretion. It found that sufficient evidence supported the conclusion that the child’s need for permanency and stability outweighed further delays inherent in waiting for the father to complete his case plan. The court affirmed the order changing the permanency plan to adoption, holding that adoption was in the child’s best interests. View "In the Interest Of: Ag, Minor Child v. The State of Wyoming" on Justia Law

A patient experienced severe complications following a routine appendectomy at a county hospital in Wyoming, leading to a diagnosis of short bowel syndrome. The surgery was performed by a hospital-employed physician. The following day, the patient suffered further abdominal issues and was transferred to another hospital, where emergency surgery resulted in substantial removal of her small intestine. The patient, initially a minor, sued the hospital and two of its physicians for medical malpractice, alleging their negligence under the Wyoming Governmental Claims Act. The hospital admitted the physicians were employees and that it was vicariously liable for their actions. As a defense, the hospital asserted that liability was limited by statute to $1 million.After these events, the District Court of Converse County denied the patient’s constitutional challenge to the statutory limitation, finding it was a limit on the waiver of immunity rather than damages. The case went to trial, where the jury awarded $8 million in total damages, with $3.2 million allocated against the hospital and the physician found liable. The court entered judgment for the full $3.2 million, despite the statutory limit. Motions for relief and further summary judgment followed, with the patient arguing the hospital’s operation of a statewide commercial healthcare enterprise should negate the statutory cap. The district court denied these motions, but clarified the hospital was not required to pay above the statutory limit.The Supreme Court of the State of Wyoming reviewed the case. It held the liability of the hospital and its physician is limited to $1 million under the Wyoming Governmental Claims Act, unless there is excess insurance coverage. The court found that operating a statewide commercial healthcare enterprise does not constitute a waiver of this statutory limitation. The judgment exceeding $1 million was reversed, and the case was remanded for entry of judgment consistent with the statutory cap. View "Memorial Hospital of Converse County v. Gates" on Justia Law

Following the parents’ divorce in 2012, ongoing custody disputes ensued over their two daughters. A 2019 order granted primary custody to the mother, with visitation for the father. In late 2024, the father filed for custody modification after the older daughter, then fifteen, reported that her mother had expelled her from the home. The father retrieved the daughter, took her to Colorado, and notified local police. Attempts at visitation and school enrollment led to further police involvement and contentious exchanges, including a physical altercation between the mother and daughter and additional conflicts involving the mother’s adult son. Throughout these events, the father sought temporary and then permanent changes to the custody order.The District Court of Laramie County initially addressed temporary custody motions and later held a hearing on the father’s petition for modification. The court appointed a guardian ad litem (GAL), who recommended counseling and ultimately a change in custody. At trial, both daughters expressed a preference for living with their mother. The GAL, however, recommended primary custody be transferred to the father. After weighing testimony and the GAL’s report, the district court found that a material change in circumstances had occurred, citing the breakdown of the mother’s relationship with the older daughter and ongoing instability. The court modified the order, awarding primary custody of both daughters to the father, with visitation for the mother.Upon review, the Supreme Court of Wyoming affirmed the district court’s decision. The court held that the district court did not abuse its discretion in finding a material change in circumstances or in concluding that awarding primary custody to the father was in the children’s best interests. The Supreme Court also granted the father costs, as permitted by rule, but not attorney’s fees, since he appeared pro se. View "Duncan v. Duncan" on Justia Law

An adult woman was staying with her elderly mother at her stepfather’s home in Evanston, Wyoming. When her stepsister arrived to retrieve their father’s wallet at his request, she was denied entry. After police arrived to keep the peace, the woman, with her mother as a passenger, slowly backed a Tesla out of the garage, striking her stepsister, who was standing in the driveway. The victim suffered bruising and hip pain, later confirmed by an emergency room visit. The woman, when asked by officers to provide her driver’s license, vehicle registration, and proof of insurance, refused, stating she was contacting her attorney. The officers eventually left and referred the matter to the district attorney.The State charged the woman with felony aggravated assault and battery, and misdemeanor interference with a peace officer. After a two-day jury trial in the District Court of Uinta County, the jury found her guilty on both counts. The court sentenced her to jail and imposed a fine. She appealed, arguing that the district court erred by refusing to give her proposed jury instruction defining “serious bodily injury,” and asserting that the evidence was insufficient to support either conviction.The Supreme Court of Wyoming affirmed the convictions. The court held that under Wyoming law, a “motorized vehicle” is a “deadly weapon” by definition, regardless of the manner in which it is used. Therefore, the district court did not err in declining to give the jury an instruction on “serious bodily injury.” The court also found that sufficient evidence supported the aggravated assault and battery conviction, as the woman knowingly caused bodily injury with a deadly weapon. Finally, the court held that her refusal to provide the requested documents to officers constituted interference under Wyoming law. The convictions were affirmed. View "Mayeux v. The State of Wyoming" on Justia Law

The case centers on a real estate transaction involving Ernest and Martha Anderson, who agreed to sell their property to Noah Messinger and Brandy Chaplin. The property was subject to a “first right of purchase” covenant held by Wyoming Fall Creek, LLC (WFC), which owned the neighboring lot. After the Andersons and Messinger entered into a purchase agreement, WFC expressed an interest in exercising its purchase right but ultimately did not finalize an agreement with the Andersons within the specified period. The Andersons and Messinger extended their closing date multiple times as they awaited resolution regarding WFC’s position. Eventually, the Andersons unilaterally terminated the contract with Messinger, citing his failure to close, and continued negotiations with WFC, which never resulted in a sale.The District Court of Teton County first reviewed the matter. It found that WFC had not timely exercised its first right of purchase, declared the Andersons’ termination of the contract with Messinger unjustified, and ordered specific performance of the purchase agreement. The court also found that WFC tortiously interfered with Messinger’s contractual rights and awarded Messinger attorney fees and costs, holding the Andersons and WFC jointly and severally liable for some of those fees, and WFC solely liable for the remainder. WFC’s actions were also deemed willful and wanton, justifying an award of punitive damages in the form of attorney fees.The Supreme Court of Wyoming reviewed the appeals. It affirmed the district court’s findings, holding that the Andersons breached the purchase agreement by terminating it without justification, and specific performance was properly ordered. The Supreme Court also upheld the finding that WFC intentionally and improperly interfered with Messinger’s contract. Finally, it concluded that the punitive damages award, including attorney fees against WFC, was not unconstitutional. The district court’s judgment was affirmed in all respects. View "Wyoming Fall Creek, LLC v. Anderson" on Justia Law

A married couple residing primarily in Jackson, Wyoming, with three children, went through divorce proceedings after a tumultuous relationship marked by substance abuse and domestic conflict. The husband, a founder and majority owner of a successful IT consulting business, and the wife, who gave up her career to raise their children, disputed issues of custody, visitation, child support, and property division. During the divorce, the wife sought and later dismissed a protective order, and the parties agreed to a temporary custody arrangement. The husband subsequently filed for divorce, and the wife secured a job in New York, intending to relocate with the children.The District Court of Teton County, following a bench trial, awarded joint legal custody with primary physical custody to the wife, allowing her to relocate. The court set detailed visitation terms for the husband and calculated child support by imputing a high income to him, based partly on prior business distributions. The court valued the marital estate, including the husband’s business, and awarded the wife 55% of the assets, justifying this as equitable due to her career sacrifices. The husband’s requests for a stay of proceedings and for enforcement of visitation were denied; the court also clarified that visitation periods could not be combined.On appeal, the Supreme Court of Wyoming held that the district court abused its discretion by improperly valuing the husband’s business interest and by including unlikely future business distributions in imputing his income for child support. The court reversed both the property division and the child support calculation, remanding for further proceedings. The Supreme Court affirmed the custody and visitation orders, finding them within the district court’s discretion and supported by the evidence. The order clarifying visitation while the appeal was pending was vacated due to lack of jurisdiction. The denial of a stay was affirmed. View "Callaway v. Callaway" on Justia Law

Charles Bunning was injured in a motor vehicle collision with Ernest Romero at an intersection in Cheyenne, Wyoming. At the time of the accident, Bunning was driving south on a through highway, exceeding the speed limit and weaving through heavy traffic. Romero, who had stopped at a stop sign on a cross street, waited for what he thought was a safe opportunity, then entered the intersection to turn left. Bunning, changing lanes and accelerating, collided with Romero’s truck as Romero crossed the highway. Both vehicles were damaged, and both drivers suffered injuries.After the incident, Bunning sued Romero for negligence. Romero counterclaimed, alleging Bunning’s negligence caused the crash, but Romero’s counterclaim was settled before trial. The District Court of Laramie County held a bench trial, concluded that both drivers breached their respective duties to operate their vehicles reasonably, and found that their negligence proximately caused Bunning’s injuries and damages. The district court found Bunning was more than fifty percent at fault, due to his speeding and unsafe driving, and under Wyoming’s comparative fault statute (Wyo. Stat. Ann. § 1-1-109(b)), barred him from recovering damages.On appeal, Bunning argued that as the preferred driver on a through highway, Romero’s failure to yield should make Romero strictly liable, and comparative fault principles should not apply. The Supreme Court of Wyoming rejected this argument, holding that the comparative fault statute applies to all negligence actions, including those involving violations of right-of-way statutes, unless the legislature has expressly provided otherwise. The Supreme Court found the district court’s application of the statute, its findings of fault, and the bar to recovery were not clearly erroneous and affirmed the judgment. View "Bunning v. Romero" on Justia Law

A man was charged after selling pills to an individual who died from a fentanyl overdose. The evidence showed the victim ingested part of a counterfeit oxycodone pill that tested positive for fentanyl, and another similar pill was found nearby. The defendant admitted to buying pills in Denver and selling two pills to the victim the night before his death, but did not admit knowing the pills contained fentanyl. He was charged with involuntary manslaughter and conspiracy to deliver a controlled substance. The defendant initially had a public defender but retained private counsel under a fee agreement that limited representation to plea negotiations unless further fees were paid.At the preliminary hearing in circuit court, the State presented evidence to establish probable cause, and the court found sufficient evidence for the case to proceed to district court. The defendant pleaded not guilty, then later entered an Alford plea to involuntary manslaughter in district court as part of a plea agreement, with the conspiracy charge dismissed. He was sentenced to 15 to 20 years. He then moved to withdraw his plea, arguing his counsel was ineffective due to the limited scope of representation, failure to challenge the elements of manslaughter, not discussing the preclusive effect of an Alford plea, not filing dispositive motions, and not advising him about the option for a public defender.The District Court of Park County denied the motion after a hearing, finding that counsel’s performance was not deficient and the defendant was adequately advised of his rights, including his right to a public defender. The Wyoming Supreme Court reviewed the denial for abuse of discretion and applied the Strickland standard for ineffective assistance of counsel. It held that the district court did not abuse its discretion; trial counsel was not ineffective, and the plea was knowing and voluntary. The Supreme Court affirmed the district court’s decision. View "Fuentes v. The State of Wyoming" on Justia Law

While the appellant was serving probation for a felony theft conviction in Crook County, Wyoming, he was charged with and pled guilty to another felony theft in Campbell County. As part of the plea agreement in Campbell County, the prosecutor agreed to recommend that the sentence for the Campbell County conviction run concurrently with the sentence from the Crook County case. After sentencing in Campbell County, the Crook County Attorney filed a petition to revoke the appellant’s probation based on the new offense. At the Crook County dispositional hearing, the prosecutor did not recommend a concurrent sentence or advocate for credit for time served in Campbell County. The district court revoked probation and imposed the original Crook County sentence, granting only credit for time previously served in Crook County.After his conviction in Crook County, the appellant filed a motion for sentence reduction, which the district court granted in part by reducing the minimum sentence but not the maximum. The appellant then appealed to the Supreme Court of Wyoming, arguing that the Crook County Attorney was bound by the Campbell County plea agreement to recommend a concurrent sentence and that not doing so breached the agreement.The Supreme Court of Wyoming held that a prosecutor in one county cannot bind a prosecutor in another county to a plea agreement without that prosecutor’s consent or authorization. The Court found that the Campbell County Attorney did not have actual or implied authority to bind the Crook County Attorney to any sentencing recommendation. As a result, the Crook County Attorney was not a party to the Campbell County plea agreement and could not have breached it. The Supreme Court of Wyoming affirmed the district court’s decision. View "Wells v. The State of Wyoming" on Justia Law

The appellant was convicted of delivery of methamphetamine, second or subsequent offense, and received a suspended sentence with three years of supervised probation. Conditions of probation included obeying Department of Corrections rules and completing any treatment required by his probation officer. After seven months, the State filed a petition to revoke probation, alleging that the appellant left required inpatient treatment at Southwest Counseling Service without completing it. The probation officer’s affidavit detailed that he left treatment against staff advice, had missed office visits, continued to use methamphetamine, and had fled from the probation office, resulting in new criminal charges.The District Court of Carbon County held a probation revocation hearing. Although the appellant initially admitted violating probation, he later claimed his attendance at inpatient treatment was voluntary. The court proceeded to an evidentiary hearing, where the probation officer testified about the appellant’s ongoing drug use, failure to attend required evaluations, and his departure from treatment. The court found by a preponderance of the evidence that he violated probation by not completing required treatment, revoked his probation, and imposed the underlying six to ten-year prison sentence, citing willful violations and unsuitability for continued probation. The appellant appealed, arguing that his due process rights were violated when the State relied on other uncharged probation violations during the dispositional phase.The Supreme Court of Wyoming reviewed the case under the plain error standard because the due process argument was not raised below. The court held there was no due process violation, explaining that written notice is required only for the specific alleged probation violation that forms the basis for revocation, not for other conduct considered during the dispositional phase. The court affirmed the district court’s order revoking probation and imposing the prison sentence, finding no clear or unequivocal rule of law was violated. View "Bustos v. The State of Wyoming" on Justia Law